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Drug and Alcohol Procedure

0 March 03, 2019

PREPARED BY REVIEWED BY APPROVED BY

REV ISSUE DATE Mohamed El-Sherbiny Sherief El-Kably Sherief El-Kably
HSE-M HSE-D HSE-D
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1. Aim

HASSAN ALLAM CONSTRUCTION is committed to providing a safe and healthy work

environment in which all workers are treated fairly, with dignity and respect. The use of drugs and
alcohol may impact on an individual’s capacity to perform work safely, efficiently and with respect,
thereby posing a risk to the health and safety of the individual and others at the workplace.

This procedure outlines the company’s commitment to a safe workplace and is aimed at preventing,
or minimising, any risk of injury or harm to the health and safety of its workers, or others at the
workplace, from the use of alcohol or drugs. It describes the standards of behaviour expected in
relation to the use of drugs and alcohol, the responsibilities of the Company, workers and others at
the workplace, and the consequences of breaching the policy.

2. Scope

This procedure applies to:

1) All employees of the company (whether full-time, part-time or casual) and all persons
performing work at the direction of, or on behalf of the company (for example contractors,
subcontractors, agents, consultants, and temporary staff) (collectively referred to as
“workers”);

2) All of the company’s workplaces and to other places where workers may be working or
representing the company.

3) All work related functions.

3. Definitions

The following are terms used in procedure:

“Drugs” - include illegal drugs, prescription or pharmacy drugs, or synthetic drugs as defined below.

“Illegal drugs” - includes:

 Any drug prohibited by Egyptian law and governmental authorities, or any other laws.
(Including foreign and international laws) to which HAC is subject or which apply to the
work performed at or for the Company;

 prescription or pharmacy drugs (as defined below) which are used without the
necessary prescription, or for non-medical purposes;

 Any synthetic drug (whether prohibited by law or not), being a psychoactive herbal and/or
chemical product which, when consumed, mimics the effects of a prohibited drug.

“Management” means the HAC’s managers, supervisors, team leaders (whichever are relevant) and
all employees with supervisory responsibilities.

“Prescription drugs” - means lawful drugs which are prescribed by a medical practitioner for a
diagnosed medical purpose and issued by a pharmacist.

“Pharmacy drugs” – means drugs which are lawfully available at Egyptian pharmacies (without
a prescription) and are required for a legitimate medical purpose.

“under the influence” – means that a person’s faculties are impaired by the use of drugs or alcohol to
the extent that the person is unfit to be entrusted with a duty they perform, or may be called on to
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perform, with efficiency and safety to themselves and others.

4. Responsibilities

4.1 Workers responsibilities

1. All workers must:

(a) Comply with this procedure;

(b) Observe all directions from the Company in regards to this procedure;

(c) Recognize that performance of duties could be affected by alcohol or drugs; and:

(d) Immediately notify management if they are aware of any breach of this
procedure by another worker. Subject to any disclosures required by law, any
notifications received by management will be treated confidentially. Failure to report
any breach of this procedure by another worker may itself constitute a breach of this
procedure.

2. Except as set out in this procedure, workers must not:

(a) Attend work, commence work, continue work or return to work having consumed
alcohol and/or drugs;

(b) Consume drugs and/or alcohol at the workplace;

(c) Must not possess, distribute, sell, use or consume illegal drugs in the workplace.
Such conduct constitutes serious misconduct. It may also constitute a criminal
offence, in which case the company may notify the police, or other appropriate
government authority;

(d) Work while under the influence of drugs or alcohol;

(e) Attend work, commence or return to work while under the influence of alcohol
and/or drugs;

(f) Consume alcohol and/or drugs during work, or at the workplace (note qualification
for prescription and pharmacy drugs below);

(g) Must not possess, distribute, sell, use or consume illegal drugs in the workplace.
Such conduct constitutes serious misconduct. It may also constitute a criminal
offence, in which case the company may notify the police, or other appropriate
government authority.

4.2 Responsibilities of Management

Management is responsible for ensuring that this procedure is implemented in their area. This includes
ensuring that:

(a) All workers are made aware and understand this procedure;

(b) Risk assessments are undertaken on work tasks in consultation with workers and/or
work health and safety representatives;

(c) The behavior of workers is observed to ensure adherence with the procedure;

(d) Any concerns or issues are addressed proactively and expediently to ensure the
health and safety of all workers;
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(e) Support is provided to workers where appropriate; and

(f) Any suspected breaches of this procedure are acted on promptly and in
accordance with this procedure.

5. Some Specific Situations

5.1 Prescription and Pharmacy drugs

5.1.1 Where a worker is taking prescription or pharmacy drugs for medical purposes, the worker
will not breach this procedure by attending work, if the worker:

(a) Takes the prescription and pharmacy drugs in accordance with the instructions of
their medical practitioner and normal directions applying to the use of those drugs;

(b) Does not misuse or abuse the use of prescription or pharmacy drugs;

(c) Ensures they are able to perform their work effectively, competently and safely;

(d) Informs themselves of the impact of consumption of alcohol with prescription and
pharmacy drugs and they limit consumption accordingly; and
(e) Checks with their medical practitioner or pharmacist about the effect of the drug on
their ability to drive vehicles operate machinery and safely perform their normal
work duties. If a workers ability to perform work competently, efficiently and
safely is affected, the worker should obtain this advice in writing from the
medical practitioner, or pharmacist, and provide it to their manager or supervisor
as soon as possible and before undertaking their work.

5.1.2 If the company suspects that the workers ability to safely perform work is affected, the
Company may take steps to address the issue in accordance with this procedure.

6 Driving company vehicles and machinery

6.1 Alcohol and illegal drugs

1. The company has a legal obligation to provide a s a f e a n d h e a l t h y w o r k i n g

environment for its workers and others in the wo rkp la ce . To ensure a safe environment,
no machinery is to be operated or used by anyone who is under the influence of alcohol, or
used or consumed illegal drugs.

2. Workers must comply with alcohol concentration limits applicable to particular duties they
perform, or may be called on to perform.

3. The company will not accept liability for any damage to a company vehicle, an injury to
another person, or damage to other property caused by a worker’s use of a company
vehicle while intoxicated from alcohol or illegal drugs. The worker will be personally liable
in such circumstances.

6.2 Prescription and pharmacy drugs

Where a worker is taking prescription or pharmacy drugs that contain a warning that the person
should not drive a vehicle or operate machinery, then that worker must not drive a company vehicle
or any vehicle, or operate machinery unless contrary specific medical advice is obtained and
confirmed in writing, from the workers medical practitioner.

If a worker is taking prescription or pharmacy drugs and feels that their ability to safely drive a vehicle
or operate machinery is affected, the worker must not drive a company vehicle, or any vehicle, or
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operate machinery and must notify their manager or supervisor immediately.

7. Smoking

Smoking is not permitted at any of the company’s workplaces, except in specifically designated
areas. These areas are: Prohibited

8. What will the company do if it suspects a worker is affected by drugs or alcohol?

If the company suspects, on reasonable grounds, that a worker is under the influence of drugs or
alcohol in breach of this procedure, the company will take steps to address the issue. Reasonable
grounds may include (but are not limited to) where the worker:

 is unable to co-ordinate their actions;

 has red or bloodshot eyes, or dilated pupils;

 smells of alcohol;

 acts contrary to their normal behaviour;

 exceeds alcohol concentration limits applicable to the task they perform or may be called on
to perform;

 is not behaving in a professional and competent manner and in accordance with the company
standards; or

 Otherwise appears to be impaired or affected by drugs or alcohol.

In such circumstances, the company may take the following actions (but is not limited to these
actions):

 Direct the worker to go home. Suitable arrangements for safe transport will be made by the
relevant manager; or

 Direct the worker to attend a medical examination to determine whether the worker is fit to
perform their duties effectively and safely. The medical examination may include a drug
and/or alcohol test, such as a breath test, blood test, urine test or oral swab. In relation to
prescription or pharmacy drugs, the Company may require evidence as part of the medical
examination about the effects and proper use of the drug. The worker may be directed to go
home following the medical examination.

 If the worker refuses to attend a medical examination, they will be directed to go home.
Refusal to attend a medical examination, refusal to go home, or providing false information
constitutes a breach of this policy and may result in action being taken against the worker,
including action as set out below under ‘Breach of policy’.

 Where a worker is sent home, or required to attend a medical examination, the worker
must report to Management (or as directed) on the next working day, or as soon as possible
once the worker is no longer under the influence of drugs or alcohol. The Company will deal
with the issue as set out below under ‘Breach of policy’. Failure to report constitutes a breach of
this procedure.

9. What will the company do if it finds drug or alcohol at the company’s workplace?

If the company finds drugs or alcohol at the workplace in breach of this procedure, the company may
take the following action, which includes but is not limited to:
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 investigate the matter in order to attempt to determine who is responsible, including by

conducting searches, as set out in this procedure;

 Require some or all workers, to undergo a medical examination in order to test for the presence
of drugs or alcohol.

Workers are required to co-operate in any investigation. Failure to co-operate, or providing false
information in an investigation, constitutes a breach of this policy and may result in action as set
out below under ‘Breach of this procedure’.

What will the company do if it suspects a worker has drugs or alcohol in their possession at
work?

If the company suspects that a worker has drugs or alcohol in their possession at work, the company
may take the following action, which includes but is not limited to:

 investigate the matter to attempt to determine whether the worker does have such drugs or
alcohol in their possession;

 Request the worker to open their locker, bag, or vehicle or to empty their pockets or jacket
for the purpose of locating any drugs or alcohol.

Workers are expected to permit such inspection and co-operate with the company’s investigation.
Failure to co-operate, or providing false information in an investigation, may result in action being
taken against the worker, as set out below under ‘Breach of this procedure’.

10. When will the company conduct drug and alcohol testing?

Definitions

The following definitions will apply to this part:

“Alcohol Screen Test” - means any analytical procedure or test which is carried out on a worker
to determine the presence and/or the concentration alcohol (including but not limited to a breath test,
urine sample, oral swab and blood test). These procedures are not limited to those which presently
exist. As new technology is developed these may also be used for alcohol testing purposes.

“Authorised Officer” - means a suitably trained, qualified and authorised person from an
Independent Testing Agency or a suitably trained, qualified and authorised person appointed by the
Company for the purposes of undertaking or arranging an Alcohol Screen Test and/or Drug Screen
Test.

“Confirmatory Test”: means any analytical procedure or test which is undertaken subsequent
to a first Alcohol Screen Test or Drug Screen Test, which is used to verify the presence of drugs or
alcohol. This may include, but is not limited to the following:
 a test applied to a second Sample of a worker’s urine;

 a test applied to any oral swab taken from a worker;

 a second Breath Test;

 Analysis of a worker’s blood.

“Drug Screen Test”: means any analytical procedure or test which is carried out on a worker to
determine the presence and/or the concentration of any drug (including but not limited to a breath
test, urine sample, oral swab and blood test). These procedures are not limited to those which
presently exist. As new technology is developed this may also be used for drug testing purposes
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“Sample” – in relation to urine, includes, if the sample is divided into portions, a portion of the
sample.

Drug and alcohol testing

1. The company may require workers to undergo testing for the presence of drugs or alcohol in
the following circumstances, with or without, prior notice:

(a) Causal based

(i) If the company suspects, on reasonable grounds, that a worker is under the
influence of drugs or alcohol in breach of this procedure.

(ii) Upon finding evidence that a worker has used, possessed, sold, solicited or
transferred drugs whilst in the workplace or while on company property.

(iii) Where the company finds drugs or alcohol in the workplace in breach of this
procedure.

(iv) Upon receipt of a report of drug or alcohol use, provided by a reliable and credible
source and confirmed by investigation, in breach of this procedure.

(v) Upon obtaining evidence that a worker has interfered with, tampered with,
falsified or destroyed an Alcohol Screen Test or Drug Screen Test.

(vi) Where a worker has previously received a positive Alcohol Screen Test or Drug
Screen Test and has refused to undergo a Confirmatory Test, he/she shall be
required to undergo subsequent testing.

(vii) Where a worker has previously received a Confirmatory Test result confirming
the use of Illegal drugs or alcohol in breach of this procedure, he/she shall be
required to undergo subsequent testing.

(viii) Where a worker notifies the company that he/she has a drug or alcohol problem.

(ix) Where a worker is taking prescription or pharmacy drugs which may affect their
ability to perform the duties and responsibilities of their position in an efficient,
competent and safe manner, without risk to the health, Welfare or safety of the
worker, or others in the workplace.

(b) Targeted Testing

Where the worker holds a position in the company in which the use of drugs or
alcohol by that worker in carrying out the duties and responsibilities of that
position would pose a risk to the health, welfare or safety of that worker,
others in the workplace.

(c) Post Incident or Near-miss

Where the investigation of an incident or near-miss determines that the worker’s

actions may have been impaired due to the use of drugs or alcohol, or the worker was
under the influence of drugs or alcohol.

(d) Random Testing

When a worker, or group of workers are randomly selected by the company or an

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Authorized person to undergo a Drug Screen test and/or Alcohol Screen test.

2. A worker, who is required to undertake a Drug Screen Test and/or Alcohol Screen Test,
will be requested to sign a consent form before taking a Drug Screen test and/or Alcohol
Screen test.

3. All information obtained through the above testing is covered by the company’s privacy
policy. The company will not use this information other than for the purposes for which it
is collected. The purposes of such monitoring and examination are to ensure the
productivity, health and safety of personnel, to apply this procedure, and for disciplinary
purposes.

4. A refusal to undergo a Drug Screen test and/or Alcohol Screen test or providing false
information, constitutes a breach of this procedure and may result in action being taken
against the worker, including action as set out below under ‘Breach of this procedure’.

11. Breach of this procedure

Workers must comply with this policy at all times.

If an employee is found to have breached this procedure, they may be subjected to disciplinary
action. The type and severity of the disciplinary action will depend upon the circumstances of the case
and the seriousness of the breach. In serious cases, this may include termination of employment.

Examples of disciplinary action that may be taken include (but are not limited to):

 performance counselling;

 a formal warning;

 suspension;

 demotion;
 Termination of employment.

Agents or contractors (including temporary contractors) of the company who are found to have
breached this procedure may have their contracts with the company terminated, or not renewed.

In circumstances where a worker’s behaviour or conduct may involve a breach of any of country
laws, the company may notify the procedure or other relevant government authority.

12. Access to support services

If an employee notifies the company that they have a drug or alcohol problem, they will be
encouraged to complete a rehabilitation program or under counselling.

13. Education and training

The company will inform and conduct training or information sessions for all employees, relating to:

(a) this procedure, including but not limited to the consequences of breaching this
procedure;

(b) the effects of alcohol and drug use (including prescription and pharmacy drugs);

(c) the risks to the health and safety of workers and others by the use of alcohol and drugs
in the workplace; and
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Where appropriate, the company will conduct induction sessions for agents, contractors and their
respective employees when they undertake work for the company in the workplace. These induction
sessions will cover:

(a) this procedure, including but not limited to the consequences of breaching this
procedure;

(b) the effects of alcohol and drug use (including prescription and pharmacy drugs);

(c) The risks to the health and safety of workers by the use of alcohol and drugs in the
workplace.

14. Worker Acknowledgement

Individual responsibilities relating to this procedure will be explained during an employee’s

induction and the Drug and Alcohol Procedure.

15. Review

This procedure will be reviewed annually during the OHS Audit Program, through consultation
with workers and health and safety representatives, or when legislative requirements change, or in the
event of a serious occurrence involving bullying.